ML23058A064
| ML23058A064 | |
| Person / Time | |
|---|---|
| Site: | Three Mile Island  |
| Issue date: | 02/22/2023 |
| From: | Hazelhoff A TMI-2 Solutions |
| To: | Office of Nuclear Material Safety and Safeguards |
| References | |
| TMI2-RA-COR-2023-0003 | |
| Download: ML23058A064 (1) | |
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TMl-2 SOLUTIONS February 22, 2023 TMl2-RA-COR-2023-0003 10 CFR 50.90 10 CFR 50.91 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001
Three Mile Island Nuclear Station, Unit 2 (TMl-2)
NRC Possession Only License No. DPR 73 NRC Docket No. 50-320
Subject:
License Amendment Request-Three Mile Island, Unit 2, Historic and Cultural Resources Review
References:
(1) NUREG-0586, Final Generic Environmental Impact Statement on Decommissioning of Nuclear Facilities: Regarding the Decommissioning of Nuclear Power Reactors, Supplement 1, dated November 2002 (ML023470304)
(2) Letter TMl2-RA-COR-2022-0022 from Lackey, M. (EnergySolutions) to Document Control Desk (U.S. NRC), "Notification of 'Amended Post-Shutdown Decommissioning Activities Report' (PSDAR) for Three Mile Island, Unit 2 in Accordance with 10 CFR 50.82(a)(7),' Revision 5" dated October 27, 2022 (ML22306A051)
In accordance with 10 CFR 50.90, "Application for amendment of license, construction permit, or early site permit," and consistent with the requirements of 10 CFR 50.82(a)(6) and the guidance set forth in NUREG-0586 ("Decommissioning GEIS," Reference 1 ), TMl-2 Solutions is submitting this License Amendment Request (LAR) for Nuclear Regulatory Commission (NRC) review of major decommissioning activities, as defined in 10 CFR 50.2, that would diminish the historic integrity (e.g., physical demolition) of the TMl-2 Solutions owned buildings previously deemed eligible for the National Register of Historic Places (NRHP) by the Pennsylvania State Historic Preservation Office (SHPO). Physical demolition of the TMl-2 Solutions owned buildings previously deemed eligible for the NRHP could result in an environmental impact not bounded by the conclusions in the Decommissioning GEIS with regard to cultural, historic, and archaeological resources if appropriate mitigation is not developed in consultation with the SHPO. This LAR is intended to support applicable historic and cultural reviews regarding the TMl-2 owned NRHP-eligible buildings in anticipation of the eventual and necessary physical demolition of the facility to be performed in accordance with the TMl-2 decommissioning project schedule described in the Post-Shutdown Decommissioning Activities Report (PSDAR)
(Reference 2).
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TMl-2 SOLUTIONS
This submittal contains no new Regulatory Commitments.
In accordance with 10 CFR 50.91(b)(1), a copy of this submittal has been sent to the Commonwealth of Pennsylvania.
I declare under penalty of perjury that the foregoing is true and correct. Executed on 22 February 2023.
Sincerely,
Digitally signed by AmyC : Amy C Hazelhoff Date: 2023.02.22 Hazelhoff 17:04:41 -05'00' Amy C. Hazelhoff Vice President, Regulatory Affairs Energy Solutions
- Evaluation of License Amendment Request
cc: w/Attachment Regional Administrator-NRG Region I NRG Lead Inspector-Three Mile Island Nuclear Station, Unit 2 NRG Project Manager - Three Mile Island Nuclear Station, Unit 2 TMl-2 Service List
Ken Robuck Director, Bureau of Radiation Protection President and CEO Department of Environmental Protection' Energy Solutions Commonwealth of Pennsylvania '
299 South Main Street, Suite 1700 Rachel Carson State Office BLDG.
Salt Lake City, UT 84111 13TH Floor P.0. Box 8469 John Sauger Harrisburg, PA 17105-8469 President and Chief Nuclear Officer Chief, Division of Nuclear Safety, Bureau Reactor D&D of Radiation Protection,
Energy Solutions Department of Environmental Protection 121 W. Trade Street, Suite 2700 Commonwealth of Pennsylvania '
Charlotte, NC 28202 Rachael Carson State Office BLDG.
Sam Bambino 13TH Floor Senior Vice President P.O. BOX 8469 D&D Operations Harrisburg, PA 17105-8469 Energy Solutions Chairman, Board of County 121 W. Trade Street, Suite 2700 Commissioners, Dauphin County Charlotte, NC 28202 112 Market Street Amy C. Hazelhoff 71h Floor Vice President, Regulatory Affairs Harrisburg, PA 17101 Energy Solutions Trevor Orth 299 South Main Street, Suite 1700 Site Decommissioning Director Salt Lake City, UT 84111 Three Mile Island Generating Station Frank Helin Route 441 South Project Director Middletown, PA 17057 TMl-2 Solutions Craig Smith 121 W. Trade Street, Suite 2700 Site Decommissioning Regulatory Charlotte, NC 28202 Assurance Lead Russ Workman Three Mile Island Generation Station General Counsel Route 441 South Energy Solutions Middletown, PA 17057 299 South Main Street, Suite 1700 Tim Devik Salt Lake City, UT 84111 TMl-2 Licensing Manager Daniel F. Stenger Three Mile Island Generating Station Hogan Lovells US LLP Route 441 South 555 13th St NW Middletown, PA 17057 Washington, D.C. 20004 ATTACHMENT 1 to TMl2-RA-COR-2023-0003 License Amendment Request Three Mile Island Nuclear Station, Unit 2 NRC Possession Only License No. DPR-73
Evaluation of License Amendment Request
In accordance with NEI 06-02, "License Amendment Request Guidelines," this attachment provides the information identified below.
1.0
SUMMARY
DESCRIPTION 2.0 DETAILED DESCRIPTION AND BASIS FOR THE CHANGE 3.0 TECHNICAL EVALUATION
4.0 REGULATORY EVALUATION
4.1 Applicable Regulatory Requirements/Criteria
4.2 No Significant Hazards Consideration 4.3 Conclusion 5.0 ENVIRONMENTAL CONSIDERATION
6.0 REFERENCES
10 Pages Follow Attachment 1 TMl2-RA-COR-2023-0003 1.0
SUMMARY
DESCRIPTION In accordance with 10 CFR 50.90, "Application for amendment of license, construction permit, or early site permit," and consistent with the requirements of 10 CFR 50.82(a)(6)(ii) and the guidance set forth in NUREG-0586 ("Decommissioning GEIS,"
Reference 1 ), TMl-2 Solutions is submitting this License Amendment Request (LAR) to request Nuclear Regulatory Commission (NRC) review of major decommissioning activities, as defined in 10 CFR 50.2, that would diminish the historic integrity (e.g.,
physical demolition) of the TMl-2 Solutions owned buildings previously deemed eligible for the National Register of Historic Places (NRHP) by the PA State Historic Preservation Office (SHPO). Physical demolition of the TMl-2 Solutions owned buildings previously deemed eligible for the NRHP could result in an environmental impact not bounded by the conclusions in the Decommissioning GEIS with regard to cultural, historic, and archaeological resources if appropriate mitigation is not developed in consultation with the SHPO. 1 This LAR is intended to support applicable historic and cultural reviews regarding the TMl-2 owned NRHP-eligible buildings in anticipation of the eventual and necessary physical demolition of the facility to be performed in accordance with the TMl-2 decommissioning project schedule described in the Post-Shutdown Decommissioning Activities Report (PSDAR) (Reference 2).
2.0 DETAILED DESCRIPTION AND BASIS FOR THE CHANGE TMl-2 Historic District Background Information A Historic Resource Survey Form (HRSF) was completed by the Pennsylvania Historic and Museum Commission (PHMC) in 2010 which stated that the TMl-2 Historic District above-ground resource (Key No. 156047) is eligible for the NRHP under Criterion A (properties significant for their association with event that have made a significant contribution to the broad patterns of history), and under Criteria Consideration G (properties that have achieved significance within the last 50 years), with a period of significance from March 28, 1979 - April 4, 1979 (Reference 3 - Attachment 4). 2 The HRSF states that "while the accident occurred at [Three Mile Island], which houses both TM I-Unit 1 and TM I-Unit 2 and their auxiliary buildings,... the resource and its subsequent boundary is only the TMI-Unit 2 and its specifically designated auxiliary buildings" (pg.
11 ). A map of the TMl-2 Historic District above-ground resource as well as a boundary survey map depicting TMl-2 Solutions owned parcels were provided to the NRC in Reference 4.
Under most circumstances, alteration of a property, including hazardous material remediation that is not consistent with the Secretary of the Interior's Standards for the Treatment of Historic Properties (36 CFR part 68) and applicable guidelines, would function to degrade a historic property's overall integrity. However, the 2010 HRSF for the TMl-2 Historic District (Reference 3 - Attachment 4) concluded that the TMl-2 Historic
1 The Decommissioning GEIS states: "In a few situations, the nuclear facility itself could be potentially eligible for inclusion in the National Register of Historic Places, especially if it is older than 50 years and represents a significant historic or engineering achievement. In this case, appropriate mitigation would be developed in consultation with the SHPO." (Reference 1) 2 The criteria for eligibility are listed in Title 36, "Parks, Forests, and Public Property," Part 60, Section 4, "Criteria for Evaluation," of the Code of Federal Regulations (36 CFR Part 60.4).
1 Attachment 1 TM I2-RA-CO R-2023-0003 District "... retains integrity, for it has been in non-operating status since the accident.
While between 1985 and 1990 an extensive program to defuel the reactor vessel and decontaminate the facility occurred... and the unit was placed in post-defueling monitored storage... no significant dismantlement has occurred" (pg. 11 ). The removal, dismantlement, and disposal of contaminated, radioactive mechanical systems and components, as well as the eventual physical demolition of the facility, is imperative to protection of public health and safety and maintaining environmental welfare, and there is no viable alternative to decommissioning that achieves this goal. Therefore, the extant character-defining features of the TMl-2 Solutions owned buildings are sufficient to convey historical integrity. As stated in the 2010 HRSF, "while... the equipment that was the 'heart' of the unit has been removed in part due to contamination and requirements of 'monitored storage,' it is still possible to get a sense of the overall feeling and association of a nuclear power plant" (pg. 11 ).
TMl-2 Solutions' Coordination with PA SHPO In preparation of the updated environmental impacts evaluation for the TM 1-2 PS DAR in accordance with 10 CFR 50.82, TMl-2 Solutions formally requested input from the PA SHPO in September 2020 regarding potential impacts to cultural resources from the TMl-2 decommissioning project (Reference 3 - Attachment 4). In this letter, TMl-2 Solutions acknowledged that the TMl-2 facility is a historic site and that cultural resources exist on Three Mile Island.
The SHPO responded in October 2020 detailing information regarding above-and below ground historic and cultural resources on Three Mile Island (Reference 3 -Attachment 4).
According to the SHPO, there are ten previously identified archaeological sites, including several presumed to have been destroyed by initial facility construction and some that retain good integrity located along the southern portion of Three Mile Island outside the operational area. 3 The SHPO's primary recommendation was that the TMl-2 decommissioning project avoid ground disturbances in the vicinities of these notable archaeological sites, as well as other areas that have not been tested, not investigated to confirm its condition, or are not obviously cut and filled or otherwise deeply disturbed.
TMl-2 Solutions plans to avoid the archaeological areas as recommended by the SHPO.
The TMl-2 Cultural Resource Protection Plan requires review of land-disturbing activities to determine if SHPO consultation is needed and if any special protection measures should be implemented prior to their execution. TMl-2 Solutions does not own the land
3 The Decommissioning GEIS (Reference 1) defines the operational area as the portion of the plant site where most or all of the site activities occur, such as reactor operation, materials and equipment storage, parking, substation operation, facility service, and maintenance. This includes areas within the protected area fences, the intake, discharge, cooling, and associated structures as well as surrounding paved, graveled, maintained landscape, or other maintained areas. Although the TMl-2 site boundary is the area under the ownership and control of TMl-2 Solutions, for the purpose of assessing decommissioning environmental impacts, the operational area at TMl-2 is considered to consist of the larger Three Mile Island site, including the north end of Three Mile Island from the fence line encompassing the south parking area northward. The operational area also includes the North and South Access Roads and the junction with the mainline railroad at the North Access Road. This area encompasses the reactor and surrounding buildings, intake structure and discharge pipe, parking lots, laydown yards, landscaped areas, and transportation infrastructure.
2 Attachment 1 TM I2-RA-CO R-2023-0003 on Three Mile Island and is therefore subject to restrictions regarding land-disturbing activities by the landowner.
Regarding above-ground resources, SHPO stated in the October 2020 letter that an updated HRSF or other documentation may be needed to better inventory the TMl-2 Historic District to determine if additional structures contribute to TMl-2's historic significance (Reference 3 - Attachment 4). TMl-2 Solutions prepared an updated HRSF for the TMl-2 Historic District to assess the SHPO's request. TMl-2 Solutions submitted an updated HRSF to the SHPO via PA-SHARE in August 2022. 4 SHPO requested additional information in September 2022 (Reference 5) but replaced this request with a subsequent letter in November 2022 (Reference 6). In Reference 6, SHPO acknowledged that the TMl-2 decommissioning project is limited to TMl-2.
TMl-2 Solutions' Historic Preservation Stewardship TMl-2 Solutions has been and remains committed to continued stewardship of TMl-2 historic and cultural resources through preservation of knowledge as well as models or artifacts of interest deemed acceptable for unconditional release in accordance with the TMl-2 Radiation Protection Program. TMl-2 Solutions has facilitated a donation of videotapes from the Post-Defueling Monitored Storage (PDMS) Library to the Pennsylvania State Archives for public access and digitization upon request (Three Mile Island Collection #MG-535, Series #MG-535-1 ). As stated in the E-Mail correspondence from SHPO to TMl-2 Solutions dated November 9, 2021, TMl-2 Solutions has been working with PHMC curators to coordinate on a plan to salvage and transfer the TMl-2 Control Room to the State Museum of Pennsylvania (Reference 7). Additionally, TMl-2 has agreed that, following completion of decommissioning and License termination, the rights and title to the Three Mile Island Nuclear Power Plant Collection of the Eberly Family Special Collections will be transferred to The Pennsylvania State University Libraries. While ample documentation and resources on the TMl-2 accident and cleanup efforts prior to entry into PDMS are already publicly available and accessible - for example, through the NRC's TMl-2 Knowledge Management Portal - TMl-2 Solutions recognizes its responsibility to ensure that the unique historic record of the TMl-2 decommissioning project is sufficiently captured.
TMl-2 Solutions has proactively developed a Cultural Resources Protection Plan and implementing procedure to provide guidance for monitoring and protecting TMl-2 Solutions' historic and cultural resources. The Plan requires that if there is a potential to cause an adverse effect, as described in 36 CFR 800.5(a)(1 ), the SHPO will be contacted to determine if any special protection measures should be incorporated into planning the decommissioning activity in order to mitigate potential the adverse effect.
3.0 TECHNICAL EVALUATION Physical demolition of the TMl-2 Solutions owned buildings previously deemed eligible for the NRHP could result in an environmental impact not bounded by the conclusions in the Decommissioning GEIS with regard to cultural, historic, and archaeological resources
4 The Pennsylvania Historic and Archaeological Resource Exchange ("PA-SHARE") is a website owned by the Commonwealth of Pennsylvania and managed by the PA SHPO.
3 Attachment 1 TM I2-RA-CO R-2023-0003
if appropriate mitigation is not developed in consultation with the SHPO. As stated in the Decommissioning GEIS:
"Impacts to cultural, historical, or archaeological resources are considered detectable if the activity has a potential to have a discernable adverse affect on the resources. The impacts are destabilizing if the activity would degrade the resource to the point that it would be of significantly reduced value to the future generations, such as physically damaging structures or artifacts or destroying the physical context of the resource in its environment." (pg. 4-67)
10 CFR 50.82(a)(6)(ii) states:
"Licensees shall not perform any decommissioning activities, as defined in § 50.2, that result in significant environmental impacts not previously reviewed."
Demolition of an NRHP-eligible property qualifies as a reasonably foreseeable adverse effect, as described in 36 CFR 800.5(a)(1 ), which must be appropriately mitigated.
Therefore, TMl-2 Solutions is submitting this LAR to support applicable historic and cultural reviews regarding the TMl-2 owned NRHP-eligible buildings in anticipation of the eventual and necessary physical demolition of the facility to be performed in accordance with the TMl-2 decommissioning project schedule described in the PSDAR (Reference 2). As stated above, considering the unique consequences of the historic event that occurred at TMl-2, the removal, dismantlement, and disposal of contaminated, radioactive mechanical systems and components, as well as the eventual physical demolition of the facility, is imperative to protection of public health and safety and maintaining environmental welfare, and there is no viable alternative to decommissioning that achieves this goal.
4.0 REGULATORY EVALUATION
4.1 APPLICABLE REGULATORY REQUIREMENTS/CRITERIA This license amendment has been evaluated to determine whether applicable regulations and requirements continue to be met. TMl-2 Solutions has determined that the proposed change would not require any exemptions or relief from regulatory requirements.
10 CFR 50.82, Termination of License 10 CFR 50.82(a)(6)(ii) states:
"Licensees shall not perform any decommissioning activities, as defined in § 50.2, that result in significant environmental impacts not previously reviewed."
TMl-2 decommissioning activities have previously been determined to be bounded by the conclusions in the Programmatic Environmental Impact Statement, NUREG-0683 (References 8-11) and the Decommissioning GEIS (Reference 1) in an NRC letter dated October 21, 2013 (Reference 12). Physical demolition of the TMl-2 Solutions owned buildings previously deemed eligible for the NRHP could result in an environmental impact not bounded by the conclusions in the Decommissioning GEIS with regard to
4 Attachment 1 TMl2-RA-COR-2023-0003
cultural, historic, and archaeological resources if appropriate mitigation is not developed in consultation with the SHPO. Therefore, TMl-2 Solutions is submitting this LAR to support applicable historic and cultural reviews regarding the TMl-2 owned NRHP-eligible buildings in anticipation of the eventual and necessary physical demolition of the facility to be performed in accordance with the TMl-2 decommissioning project schedule described in the PSDAR (Reference 2).
36 CFR 800, Protection of Historic Properties The requirements of the Section 106 process are outlined in 36 CFR 800, Protection of Historic Properties, under the National Historic Preservation Act (NHPA).
36 CFR 800.1 (a) states:
"Section 106 of the National Historic Preservation Act requires Federal agencies to take into account the effects of their undertakings on historic properties and afford the [Advisory Council on Historic Preservation (ACHP)] a reasonable opportunity to comment on such undertakings.... The Section 106 process seeks to accommodate historic preservation concerns with the needs of Federal undertakings through consultation among the agency official and other parties with an interest in the effects of the undertaking on historic properties, commencing at the early stages of project planning."
Per 36 CFR 800.16(1)(1 ), "Historic property" means any prehistoric or historic district, site, building, structure, or object included in, or eligible for inclusion in, the NRHP maintained by the Secretary of the Interior. Per 36 CFR 800.16(1)(2), the term "eligible for inclusion in the National Register" includes both properties formally determined as such in accordance with regulations of the Secretary of the Interior and all other properties that meet the National Register criteria. The TMl-2 Historic District was designated as eligible for the NRHP in 2010 by the SHPO under Criterion A, Criteria Consideration G and maintains its historic integrity; therefore, the term "historic property" applies. A map of the TMl-2 Historic District was provided to the NRG in Reference 3.
10 CFR 50.51, "Continuation of License" 10 CFR 50.51(b) states:
"(b) Each license for a facility that has permanently ceased operations, continues in effect beyond the expiration date to authorize ownership and possession of the production or utilization facility, until the NRG notifies the licensees in writing that the license is terminated. During such period of continued effectiveness, the licensee shall -
(1) Take actions necessary to decommission and decontaminate the facility and continue to maintain the facility including, where applicable, the storage, control and maintenance of the spent fuel, in a safe condition, and
5 Attachment 1 TMl2-RA-COR-2023-0003
(2) Conduct activities in accordance with all other restrictions applicable to the facility in accordance with the NRG regulations and the provisions of the specific 10 CFR part 50 license for the facility."
TMl-2 Solutions will continue to conduct activities in accordance with the License until the NRG notifies TMl-2 Solutions in writing that the License is terminated.
10 CFR 50.2, "Definitions" "Major decommissioning activity means, for a nuclear power facility, any activity that results in permanent removal of major radioactive components, permanently modifies the structure of containment, or results in dismantling components for shipment containing greater than class C waste in accordance with§ 61.55 of this chapter."
TMl-2 Solutions will perform major decommissioning activities in accordance with this definition and as allowed by the License.
4.2 NO SIGNIFICANT HAZARDS CONSIDERATION TMl-2 Solutions has evaluated whether a significant hazards consideration is involved with the proposed amendment by focusing on the standards set forth in 10 CFR 50.92, "Issuance of amendment," as discussed below:
- 1) Does the proposed amendment involve a significant increase in the probability or consequences of an unanticipated event previously evaluated?
Response: No.
This LAR will support applicable historical and cultural reviews prior to performance of major decommissioning activities that would diminish the historic integrity of the TMl-2 Solutions owned buildings. This license amendment will not affect operating procedures or administrative controls that have the function of ensuring the safe management of Fuel Bearing Material or decommissioning of the facility. Therefore, the proposed change would not involve a significant increase in the probability or consequences of an unanticipated event previously evaluated.
- 2) Does the proposed amendment create the possibility of a new or different kind of accident from any unanticipated event previously evaluated?
Response: No.
This LAR will support applicable historical and cultural reviews prior to performance of major decommissioning activities that would diminish the historic integrity of the TMl-2 Solutions owned buildings. This license amendment will not create the possibility of a new or different kind of accident due to credible new failure mechanisms, malfunctions, or accident initiators not considered in the
6 Attachment 1 TM I2-RA-CO R-2023-0003 design and licensing bases. Therefore, the proposed change would not create the possibility of a new or different kind of accident from any unanticipated event previously evaluated.
- 3) Does the proposed amendment involve a significant reduction in a margin of safety?
Response: No.
This LAR will support applicable historical and cultural reviews prior to performance of major decommissioning activities that would diminish the historic integrity of the TMl-2 Solutions owned buildings. This license amendment would not affect systems or components supporting source term reduction or decommissioning activities, nor would it result in a change in initial conditions or any other parameter affecting decommissioning activity accident analyses.
Therefore, this LAR does not involve a significant reduction in a margin of safety.
4.3 CONCLUSION
S Based on the considerations discussed above: 1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, 2) such activities will be conducted in compliance with the NRC's regulations, and 3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public. TMl-2 Solutions has concluded that the proposed license amendment supports a finding of no significant hazards consideration under the standards set forth in 10 CFR 50.92.
5.0 ENVIRONMENTAL CONSIDERATION As stated above, the Decommissioning GEIS notes that if a nuclear facility itself is or could be potentially eligible for inclusion in the NRHP, appropriate mitigation would be developed in consultation with the SHPO. Under the NHPA, mitigation is determined through the Section 106 process, which seeks to accommodate historic preservation concerns with the needs of Federal undertakings through consultation among the agency official and other parties with an interest in the effects of the undertaking on historic properties. Impacts to cultural, historic, or archaeological resources are considered detectable if an activity has a potential to have a discernable adverse effect on the resources. The impacts are destabilizing if the activity would degrade the resource to the point that it would be of significantly reduced value to the future generations, such as physically damaging structures or artifacts or destroying the physical context of the resource in its environment (Reference 1 ).
Physical demolition of the TMl-2 Solutions owned buildings previously deemed eligible for the NRHP could result in an environmental impact not bounded by the conclusions in the Decommissioning GEIS with regard to cultural, historic, and archaeological resources if appropriate mitigation is not developed in consultation with the SHPO and qualifies as a reasonably foreseeable adverse effect under 36 CFR 800.5(a)(1 ). This LAR requests NRC review of major decommissioning activities, as defined in 10 CFR 50.2, which would
7 Attachment 1 TMl2-RA-COR-2023-0003
diminish the historic integrity of the TMl-2 Solutions owned buildings (e.g., removal by physical demolition) previously deemed eligible for the NRHP by the SHPO. As stated above, considering the unique consequences of the historic event that occurred at TMl-2, the removal, dismantlement, and disposal of contaminated, radioactive mechanical systems and components, as well as the eventual physical demolition of the facility, is imperative to protection of public health and safety and maintaining environmental welfare, and there is no viable alternative to decommissioning that achieves this goal.
Criteria for a Finding of No Significant Impact
- 1) There is reasonable assurance that the health and safety of the public will not be endangered by the decommissioning activity.
This LAR will support applicable historical and cultural reviews prior to performance of major decommissioning activities that would diminish the historic integrity of the TMl-2 Solutions owned buildings previously deemed eligible for the NRHP by the SHPO. The eventual physical demolition of the TMl-2 facility is a necessary consequence of the decommissioning project, of which there is no viable alternative. Therefore, there is reasonable assurance that the health and safety of the public will not be endangered by performance of the decommissioning activities described in this LAR.
- 2) There is reasonable assurance that such activity will be conducted in compliance with the Commission's regulations.
This LAR will support applicable historical and cultural reviews prior to performance of major decommissioning activities that would diminish the historic integrity of the TMl-2 Solutions owned buildings previously deemed eligible for the NRHP by the SHPO. As stated above, TMl-2 Solutions will perform major decommissioning activities in accordance with the 10 CFR 50.2 definition and as allowed by the License and will continue to conduct activities in accordance with the License until the NRC notifies TMl-2 Solutions in writing that the license is terminated. Therefore, there is reasonable assurance that the decommissioning activities as described in this LAR will be conducted in compliance with the Commission's regulations.
- 3) The issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.
This LAR will support applicable historical and cultural reviews prior to performance of major decommissioning activities that would diminish the historic integrity of the TMl-2 Solutions owned buildings previously deemed eligible for the NRHP by the SHPO. As stated in (1 ), there is no viable alternative to the eventual physical demolition of the TMl-2 facility. Physical demolition is a necessary consequence of the decommissioning project, which is imperative to protection of public health and safety and maintaining environmental welfare.
8 Attachment 1 TMl2-RA-COR-2023-0003
Therefore, the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.
6.0 REFERENCES
- 1. NUREG-0586, Final Generic Environmental Impact Statement on Decommissioning of Nuclear Facilities: Regarding the Decommissioning of Nuclear Power Reactors, Supplement 1, dated November 2002 (ML023470304).
- 2. Letter TMl2-RA-COR-2022-0022 from Lackey, M. (EnergySolutions) to Document Control Desk (U.S. NRC), "Notification of 'Amended Post-Shutdown Decommissioning Activities Report' (PSDAR) for Three Mile Island, Unit 2 in Accordance with 10 CFR 50.82(a)(7),' Revision 5" dated October 27, 2022 (ML22306A051)
- 3. Letter TMl2-RA-COR-2021-0004 from van Noordennen, G. P. (EnergySolutions) to Document Control Desk (U.S. NRC), "Notification of 'Amended Post-Shutdown Decommissioning Activities Report' (PSDAR) for Three Mile Island, Unit 2 in Accordance with 10 CFR 50.82(a)(7), Revision 4" dated March 17, 2021 (ML21084A229)
- 4. Letter TMl2-RA-COR-2023-0001 from Hazelhoff, A. C. (EnergySolutions) to Document Control Desk (U.S. NRC), "License Amendment Request - Three Mile Island, Unit 2, Decommissioning Technical Specifications, Response to Request for Additional Information Regarding Historical and Cultural Resources," dated January 20, 2023
2021 PR03278.002, TMl-2 Decommissioning Project, Dauphin County, Pennsylvania, Nuclear Regulatory Commission, Conoy Township, Lancaster County," dated September 12, 2022 (ML22343A148)
2021 PR03278.006, TMl-2 Decommissioning Project, Dauphin County, Pennsylvania, Nuclear Regulatory Commission, Conoy Township, Lancaster County," dated November 17, 2022 (ML22343A150)
- 7. E-Mail from Lowery, A. (PA SHPO) to van Noordennen, G.P. and Pell. H (EnergySolutions), "TMI Section 106 and Control Room Salvage," dated November 9, 2021 (ML22343A161)
- 8. NUREG-0683, "Programmatic Environmental Impact Statement Related to Decontamination and Disposal of Radioactive Wastes Resulting from March 28, 1979 Accident Three Mile Island Nuclear Station, Unit 2," Volume 1 and Volume 2, dated March 1981 (ML20003C732).
- 9. NUREG-0683 Supplement 1, "Programmatic Environmental Impact Statement Related to Decontamination and Disposal of Radioactive Wastes Resulting from March 28, 1979 Accident Three Mile Island Nuclear Station, Unit 2," (Occupational Radiation Dose), dated October 1984 (ML20106J132).
- 10. NUREG-0683 Supplement 2, "Programmatic Environmental Impact Statement Related to Decontamination and Disposal of Radioactive Wastes Resulting from
9 Attachment 1 TMl2-RA-COR-2023-0003 March 28, 1979 Accident Three Mile Island Nuclear Station, Unit 2," (Disposal of Accident-Generated Water), June 1987 (ML20235A112).
- 11. NUREG-0683, Supplement 3, "Programmatic Environmental Impact Statement Related to Decontamination and Disposal of Radioactive Wastes Resulting from March 28, 1979 Accident Three Mile Island Nuclear Station, Unit 2," Supplement 3, (Post-Defueling Monitored Storage and Subsequent Cleanup) dated August 1989 (ML20247F778).
12.Letter from Buckley, J.T. (U.S. NRC) to Hardin, P. (GPU Nuclear), "Request for Additional Information on Three Mile Island Nuclear Station Unit 2 - Post Shutdown Decommissioning Activities Report," dated October 21, 2013 (ML13266A285)
10